Health plans - design

Points to Keep in Mind When Introducing Medical Plan Choice"[1] Offering medical plan choice is a journey -- have a multi-year plan.... [2] Make sure you aren't offering your employees medical plan choice in name only.... [3] Inertia is the enemy of progress -- take steps to prevent it.... [4] If you build it, will they come? Provide decision support for employees." (Fidelity Health Marketplace)

Sen. Cassidy's Repeal-and-Replace Plan Is 'Only Game Left'"The Cassidy-Graham-Heller legislation, which hasn't yet been scored by the [CBO], would scrap the ACA's individual and employer mandates to buy health insurance while largely block-granting Medicaid funding for states." (InsuranceNewsNet.com)

2017 Midyear HSA Research Report (PDF)"The number of HSA accounts surpassed 21 million, holding about $42.7 billion in assets, a year over year increase of 23% for HSA assets and 16% for accounts ... HSA investment assets reached an estimated $6.8 billion in June, up 44% year over year. The average investment account holder has a $15,146 average total balance ... Health plan partnerships continued as the leading driver of new account growth, accounting for 36% of new accounts opened in 2017 so far." (Devenir)

CMS Releases Hospice Comparison Website"The site displays information in a ready-to-use format and provides a snapshot of the quality of care each hospice facility offers to its patients.... By ensuring patients have the information they need to understand their options, CMS is helping individuals make informed healthcare decisions for themselves and their families based on objective measures of quality." (Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS])

Bringing Telemedicine to the Workplace: What Employers Should Know"Providing telemedicine services to employees can raise a number of legal issues -- the most common being compliance with federal laws such as ERISA, COBRA and HIPAA, as well as state laws concerning medical licensure and practice and informed consent. Employers offering access to a telemedicine program for all employees -- regardless of group health plan enrollment status -- could inadvertently create a separate ERISA group health plan." (The Akron Legal News)

Accountable Care Organizations: The Next Wave?"HR professionals working directly with ACOs or accessing them through a traditional health insurance network need to review their financial and health outcomes reports and ask plenty of questions ... [What] types of fees your company will pay? What types of savings and outcomes are being generated? How? How much of provider compensation is tied to the delivery of care? What different quality metrics are being used to measure performance? ... While ACOs provide a legal framework for health plans and employers that's compliant with federal health regulations, successful ACOs encourage providers to cut costs through serious financial incentives[.]" (Human Resource Executive Online)

Recess Update on the ACA and Its Repeal and Replacement"To date, ACA rules on employers sponsoring group and individual health care coverage appear to have received little attention from regulators, and most of the requirements remain in place.... This means, among other things, that the Summary of Benefits and Coverage Rule template, updated effective April 1, 2017, must be addressed by employer plans and, as of now, employer reporting obligations will continue in January 2018." (Ballard Spahr LLP)

If Cost-Sharing Reduction Payments End, States Can Use 1332 Waivers to Fund Their Own"Creating a State-administered CSR mechanism will undoubtedly require expenditure from the State. While some will argue that the limited resources available in State budgets would render the idea all but theoretical, it would be beneficial to examine how States can use Section 1332 of the ACA to fund -- and potentially profit from -- providing CSR." (Health Affairs)

Getting Tech Employees Engaged in Worksite Wellness"Technology employees, like many office workers, are challenged with high stress and long hours, putting them at risk for the 'sitting disease' -- or sitting all day at their desk -- resulting in increased risk for poor health and disease.... [1] Change their perception of how much time it takes to be healthy -- offering short, convenient sessions for fitting in fitness.... [2] Play to a common characteristic found in tech employees: Competitiveness.... [3] Tech employees naturally are comfortable with technology -- and expect to use it[.]" (HealthFitness)

[Opinion] Insurers, Providers and Employers on a Collision Course"Historically, insurers have been able to use competing health providers as leverage against each other in their provider negotiations.... Cost transparency tools and claims analysis are showing us that there are large cost differences between certain systems.... Employers and insurers are gearing up for a fight with the hospital systems and the dispute will undoubtedly spill over to state lawmakers as restrictive contractual covenants will be challenged." (Frenkel Benefits)

[Opinion] Subsidizing Health Insurance Cannot Ever Get U.S. to Universal Coverage"This study looked at low-income individuals and showed that ... the willingness to pay for a percentage of the premium is far below the insurers' average costs. Even with 90% of the premium subsidized, 20% of the individuals would remain uninsured, and the percent insured dropped off rapidly as the individuals' share increased." (Physicians for a National Health Program [PNHP])

Subsidizing Health Insurance for Low-Income Adults: Evidence from Massachusetts"Using administrative data from Massachusetts' subsidized insurance exchange, ... [the authors] estimate willingness to pay and costs of insurance among low-income adults. As subsidies decline, insurance take-up falls rapidly, dropping about 25% for each $40 increase in monthly enrollee premiums. Marginal enrollees tend to be lower-cost, consistent with adverse selection into insurance. But across the entire distribution we can observe -- approximately the bottom 70% of the willingness to pay distribution -- enrollee willingness to pay is always less than half of own expected costs." (National Bureau of Economic Research [NBER])

[Opinion] How Federal Regulators Can Reform Obamacare Without Help from Congress"With health reform at an impasse in Congress for the time being, here are four ideas that HHS and the states can explore and expand. [1] Expand state reinsurance options.... [2] Allow innovative pilot plan designs for high cost patients.... [3] Give states more authority on how exchanges are run -- including contracting out to a private exchange.... [4] [A]llow unused federal tax credits to cover the employees' portion of insurance for small-to-medium sized businesses." (Manhattan Institute for Policy Research)

[Opinion] Re-Thinking Employer-Provided Health Benefits"Employer-sponsored coverage is shrinking.... What's covered and who is covered is shrinking.... Employees are paying more of the cost.... Employers blame hospitals and drug companies for excess costs.... Employers are implementing new strategies to rein in their costs.... Two issues have regulators' attention: Disparity in employee access ... Contracts with providers ... But beyond these issues, cost is the overriding employer concern that's likely to define the future for employer sponsored health benefits." (Paul Keckley)

Seventh Circuit Upholds ERISA Plan's Forum Selection Clause"As the Seventh Circuit noted, ... only one other appellate court (the Sixth Circuit, covering Kentucky, Michigan, Ohio, and Tennessee) has ruled on this question ... Moreover, neither the Sixth Court's Smith decision nor this one were unanimous, and the DOL continues to challenge the validity of forum selection clauses.... As a result, employers in jurisdictions outside the Sixth and Seventh Circuits should bear in mind that there is less certainty regarding whether their plan venue provisions will be enforced." [In re Mathias, No. 16-3808 (7th Cir. Aug. 10, 2017)] (Thomson Reuters Practical Law)

Seventh Circuit: Caterpillar Health Plan Can Limit Court Choice"In upholding a forum selection clause in Caterpillar Inc.'s health plan, the U.S. Court of Appeals for the Seventh Circuit on August 10 became the second federal circuit court to say that these clauses -- which require litigation over plan benefits to be brought in the employer's preferred court -- don't violate [ERISA]. The Sixth Circuit reached the same conclusion in a 2014 decision[.]" [In re Mathias, No. 16-3808 (7th Cir. Aug. 10, 2017)] (Bloomberg BNA)

Freedom Caucus Brings Petition to House Floor in Attempt to Repeal Obamacare"Among other things, the bill would remove language in IRC Sec. 223(d)(2) that requires drugs to be prescribed or to be insulin to be HSA-qualified medical expenses, and change the additional tax on HSA distributions not used for qualified medical expenses from the current 20 percent to 10 percent." (Ascensus)

The HSA in Your Future: Defined Contribution Retiree Medical Coverage"[O]nly 24% of employers with 200 or more employees offer retiree health coverage ... The percentage of smaller employers offering retiree medical coverage is much, much less.... [L]ess than 5% of America's workers have access to and save on a tax-favored basis for future medical expenses -- including HSA-qualifying expenses[.]" (Plan Sponsor Council of America [PSCA])

[Discussion] What's a Reasonable Fee for Assistance with RFP for New PBM?"Looking for opinions on reasonable fee range for one of the big consulting houses to conduct an RFP to help us select a new PBM. We are a 40,000+ employee company operating in almost all states. Pharmacy is currently carved in with medical. Also need reasonable fee for implementation and ongoing oversight of PBM." (BenefitsLink Message Boards)

[Official Guidance] Text of CMS Q&A on Risk Adjustment Methodology and Rate Filing Deadlines (PDF)"What changes will be made to the risk adjustment methodology to account for recent rating practices that assume issuers of silver-level QHPs facing increased liability for enrollees in cost-sharing reduction plan variations? ... Given these requests from the States, will CMS provide further flexibility on filing deadlines to permit issuers to account for these rating changes?" [Unnumbered document, Aug. 10, 2017] (Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS])

Comparing Discounts in a Self-Insured Arrangement"In a self-insured plan, where 85% or more of cost is the actual payments made for medical claims, one of the most important factors to consider is the network; which one will provide the best access and which will yield the best provider discounts.... It's more critical to look closely at the in-network statistics for noise such as inclusion of repricing networks or the exclusion of certain ancillary providers." (Frenkel Benefits)

Employers Are Revamping Benefits Strategies to Outmaneuver Competitors and Become Destination Employers"[R]educing healthcare costs remains the main driver for offering a wellness program (60 percent) ... The need to appeal to younger workers with parental leave policies has prompted a discussion about supporting the total wellbeing of employees as they try to solve the work-life equation.... [N]early half (48 percent) of employers use auto-enrollment in retirement plans to help employees improve savings, [but] only 37 percent are measuring retirement readiness." (Wolters Kluwer Law & Business)

[Opinion] The Case for Abolishing Obamacare's Individual Mandate"[T]he individual mandate is not the only way to prevent people from waiting to get sick before purchasing health insurance coverage. Policymakers could allow individuals to opt out of regulatory guarantees for pre-existing conditions or impose waiting periods for those who fail to maintain continuous coverage." (U.S. News & World Report)

[Opinion] Suggestions for a Bipartisan Approach on Health Care"[B]ipartisan discussion should focus [on:] [1] Stabilize the market In the short run.... [2] Improve support for the middle class.... [3] Strike a compromise on medicaid expansion and reform.... [4] Explore alternatives to the individual mandate.... [5] Make consumer-directed health plans available to all individual insurance market enrollees.... [6] Establish automatic enrollment.... [7] Replace the Cadillac Tax with a 'tax cap'.... [8] Improve the ACA's delivery system reform agenda.... [9] Repeal the IPAB." (Joseph Antos and James Capretta, in Health Affairs)

The ACA Stability 'Crisis' in Perspective"84% of the enrollees in the marketplaces -- about 8.7 million people -- receive premium subsidies under the ACA and are insulated from these premium hikes. However, roughly 6.7 million people -- the ones who buy ACA-compliant plans inside or outside the marketplace and aren't subsidized -- will feel the full brunt of premium increases. They'll be hit if the uncertainty is not resolved and the rates do not come down before they are finalized. In many cases, there is as much as a 20 percentage point swing or more in rates depending on whether the CSRs are paid." (Drew Altman, Kaiser Family Foundation, via Axios)

Gaps in Planning Impact Ability to Manage Benefits Costs"65% of respondents say they spend less than a year developing their annual benefit plan changes.... 81% of respondents selected managing costs as one of their three primary benefits priorities; 50% list helping workers make better benefits decisions.... While four out of five companies say one of their goals is to manage health benefits costs better, 40% do not plan to implement any new cost management programs in the next 12 to 18 months and 50% believe that they've done all they can reasonably do to manage costs.... 54% cite employee morale as their most improved metric from implementing wellness programs." (HR Daily Advisor)

[Opinion] Making the Exchanges More Competitive by Bringing Medicare Into the Fold"Introducing Medicare wouldn't require significant new spending. It would provide competition in counties with only one or two insurers. And it would ensure that all counties would always have at least one insurance option available. What's more, Medicare could be used to provide new private plan options by allowing Medicare Advantage private plans to offer coverage to nonelderly Americans through the exchanges." (Gerard Anderson, Jacob S. Hacker, and Paul Starr, in Health Affairs)

Tips to Create a Culture of Health (PDF)"Employees are three times more likely to take action to improve their health when their employer promotes a workplace environment that supports health and well-being, or a 'culture of health.' [1] Lead by example ... [2] Offer program choices ... [3] Focus on strategic communications ... [4] Use digital tools ... [5] Reward healthier behaviors ... [6] Measure success." (ActiveHealth Management)

How Narrow Networks Can Reduce Plan Costs"Some health plans create multiple narrow networks to choose from that get progressively narrower.... Another approach is for the insurer to create two tiers of in-network providers -- often called 'designated' and 'non-designated' -- with no out-of-network coverage.... This final kind of narrow network structure, which grew in popularity after the ACA was enacted, is the accountable care organization (ACO)." (Fidelity Health Marketplace)

2018 Projected Health Insurance Exchange Coverage Map, Updated Aug. 9, 2017 (PDF)[CMS] has posted an update to the Health Insurance Exchanges Issuer County Map. This map is of projected issuer participation on the Health Insurance Exchanges in 2018 based on the known issuer public announcements through August 9, 2017. Participation is expected to fluctuate and does not represent actual Exchange application submissions. (Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS])

Lawmakers Regroup to Consider Possible ACA Fix"A group of more than 40 bipartisan House members ... vowed to [1] create a stability fund that states could use to reduce premiums and limit insurers' losses; [2] change the requirement that employers provide coverage to affect companies with 500 or more employees, as opposed to the current 50-employee minimum; and [3] repeal the medical device tax[.]" (InsuranceNewsNet.com)

[Opinion] Has Obamacare Become Trumpcare?"[O]pen enrollment for the ACA's marketplaces begins November 1, and insurers have to decide by late September whether they will participate. There are a host of actions the administration could take to make it successful. [1] Provide clarity around the rules ... [2] [Maintain] outreach and consumer assistance ... [3] [Encourage] insurers to participate ... [4] [G]ive states flexibility to experiment through Medicaid waivers and ACA waivers under section 1332 of the law." (JAMA Forum)

Big Employers Take U-Turn, Vow to Continue Offering Health Insurance"Two surveys of large employers ... show companies continue to try to control costs while backing away from shrinking or dropping health benefits.... That's a marked change from three years ago, when many big employers -- those with 1,000 employees or more -- contemplated ending medical benefits and shifting workers to the [ACA]'s marketplaces." (Kaiser Health News)

Large U.S. Employers Project Cost of Health Benefits Will Surpass $14,000 Per Employee in 2018"Employers will cover nearly 70% of those costs while employees will bear about 30%, or nearly $4,400 in 2018. For the second consecutive year, employers ranked specialty pharmacy (26%) as the top driver.... Virtually all employers (96%) will make telehealth services available in states where it is allowed next year.... Twenty-one percent of employers plan to promote ACOs in 2018 but that number could double by 2020 as another 26% are considering offering them.... More than half of employers (54%) will offer onsite or near site health centers in 2018 and that number could increase to nearly two-thirds by 2020." (National Business Group on Health [NBGH])

More Smaller Employers Self-Insuring Health Benefits"As the [ACA] drives up premiums because of more requirements and taxes, self-insurance has become a more attractive option because it is often less expensive than purchasing fully insured plans ... But some policy analysts argue the companies that are self-insuring generally have healthy employees and that leaving the fully insured risk pool results in higher costs for fully insured companies with older, less healthy employees." (Bloomberg BNA)

Telemedicine Expanding Rapidly"According to one recent survey, telemedicine services (i.e., remote delivery of healthcare services using telecommunications technology) among large employers (500 or more employees) grew from 18% in 2014 to 59% in 2016. Common selling points touted by telemedicine vendors include reduced health care costs and employee convenience. However, state licensure laws imposing restrictions on telemedicine practitioners can often limit the value (or even availability) of telemedicine services to employees. But that seems to be changing." (Benefits Bryan Cave)

Supporting the Individual Health Insurance Market"[T]he current market status can be traced back to a series of regulatory and implementation failures that served to undermine the market including lax enforcement of the individual mandate, incomplete payouts to insurers, and regulatory uncertainty. Looking ahead, a set of regulatory and legislative changes, alongside the assurance of operational and regulatory certainty for issuers, could put it back on track." (Michael Chernew and Christopher Barbey, in Health Affairs)

Seven Implications of Ending Obamacare's Cost Sharing Reduction Payments"[1] The decision would affect only subsidized plans sold in the exchange market ... [2] As only Silver-level plans qualify for cost sharing reductions, it would also not affect customers buying plans at other levels of coverage ... [3] [T]he number of affected individuals ... would be about 5.8 million.... [4] [I]nsurers offering coverage in the Obamacare exchanges would still be required by law to reduce cost sharing amounts for qualified enrollees.... [5] [I]nsurers couldn't increase enrollee's premiums immediately -- that would have to wait until the next plan year.... [6] Taxpayers would pick up almost all of the additional premium cost.... [7] Continuing these subsidies will not help stabilize the broader individual-market, because the cost sharing reductions apply only to plans purchased through the Obamacare exchanges." (The Heritage Foundation)

Appellate Ruling Deals Setback to Opponents of Contraceptive Coverage Mandate"[T]he case involved two issues: [1] whether the government must exempt an employer that objects on moral, as opposed to religious, grounds to contraceptive coverage from the requirement to provide such coverage, and [2] whether individuals who object to contraceptives on religious grounds must be allowed to purchase insurance that does not cover contraceptives. Two of the three judges on the appellate panel answered both questions in the negative." [Real Alternatives v. HHS, No. 16-1275 (3d Cir. Aug. 4, 2017)] (Health Affairs)

[Opinion] An Open Letter to the Senate HELP Committee"[T]he individual insurance market is only 4% of the 285 million who are insured.... The stability of individual insurance market is a legitimate issue but it's small relative to policies and strategies that impact every employer and household. Your charter must be bigger than reducing risks for insurers; it must be about the viability and sustainability of the entire health system." (Paul Keckley)

[Guidance Overview] What's Next for Plan Sponsors After Failed Congressional Attempts to Repeal/Replace the ACA?"Although the IRS has acknowledged glitches in the ACA reporting system, the IRS has confirmed that an applicable large employer is still subject to an employer shared responsibility payment if it (i) fails to offer coverage to 95% of its full-time employees or (ii) has a full-time employee who obtains coverage on the insurance marketplace and receives premium assistance or a tax credit, and the employer's coverage is not affordable or did not provide minimum value.... Congress can still pass narrowly tailored relief in the form of standalone legislation or by including reforms in a bipartisan bill to stabilize the insurance markets.... [R]egulatory guidance from the departments with ACA oversight ... may give employers relief[.]" (Winston & Strawn LLP)

Breaking Down the Graham-Cassidy ACA Replacement Proposal"In the aftermath of the HCFA's defeat, the only remaining proposal that appears to have any chance at seeing a Senate vote is a complex overhaul of the current ACA landscape from Republican Sens. Lindsey Graham, R-S.C., and Bill Cassidy, R-La. The crux of the Graham-Cassidy amendment is to replace the ACA's insurance subsidies and Medicaid expansion with comparatively smaller block grants to states." (Trucker Huss)

The Future of Healthcare Reform: Republican Efforts Stall in the Senate (PDF)"Senate Republicans are now essentially out of options in the near-term, and shortly after the defeat of the bill Majority Leader McConnell conceded on the Senate floor that they would not be able to repeal the ACA. However, ... the dynamics around the healthcare debate in Washington are volatile, with a variety of proposals being floated by different factions in Congress, and President Trump continuing to make passage of an ACA repeal/replace bill a top priority, threatening a defunding of the ACA's cost sharing reductions to spur action[.]" (Groom Law Group)

Ninth Circuit: An SPD and Trust Agreement Together a Plan Make"Although it is not uncommon, especially in the self-funded health plan context, for a single document to function as both an SPD and plan document, this case illustrates some of the pitfalls of that approach. The SPD in this case (though purporting, by its terms, to serve as both the SPD and plan document) fell short in satisfying ERISA's requirements for a plan document. Only by coupling the SPD with the plan's trust agreement was the Ninth Circuit able to conclude that an ERISA plan existed." [Mull v. Motion Picture Ind. Health Plan, No. 15-56246 (9th Cir. Aug. 1, 2017)] (Thomson Reuters Practical Law)

Obamacare Death Spiral? Off-Exchange Enrollment Down 29 Percent"As of March 2017, the individual insurance market totaled 17.6 people. That is down from 20.2 million one year prior. This is a decrease of 2.6 million people, a 13 percent drop in the size of the overall individual-health-insurance market. 12.2 million bought their health insurance on the state- and federally run Obamacare exchanges. 5.4 million people bought their insurance off of the Obamacare exchanges." (National Review)

The 5 A's of Access for Employer-Sponsored Healthcare"Acceptability is the critical element of access and drives many of the disparities in healthcare and health outcomes we experience in the US today. Yet this dimension of the access conversation rarely gets attention." (Mercer)

What Happens If the Administration Stops Cost-Sharing Reduction Payments to Insurers?"Some insurers might well decide that the government is an unreliable partner and give up on the exchanges for 2018.... The individual market makes up a small part of the business of large insurers; even though it has become more profitable in the recent past, some insurers might conclude that the premium increases that would be needed to make up for the loss of the CSRs would drive healthy enrollees out of the individual market. Rather than deal with a deteriorating risk pool, they might leave the individual market entirely[.]" (Timothy Jost, in Health Affairs)

2018 Projected Health Insurance Exchange Coverage Map, Updated Aug. 2, 2017 (PDF)"[CMS] has posted an update to the to the Health Insurance Exchanges Issuer County Map. This map is of projected issuer participation on the Health Insurance Exchanges in 2018 based on the known issuer public announcements through August 2, 2017. Participation is expected to fluctuate and does not represent actual Exchange application submissions." (Centers for Medicare & Medicaid Services [CMS], U.S. Department of Health and Human Services [HHS])

U.S. Employers Expect Health Care Costs to Rise by 5.5% in 2018"Employers expect health care costs to increase by 5.5% in 2018, up from a 4.6% increase in 2017 ... In the face of these continued cost pressures, including employee affordability, employers plan to step up cost management strategies over the next three years, including evaluation of emerging health care delivery solutions and improved patient navigation and health engagement." (Willis Towers Watson)

Latest Motion in House v. Price Has Significant Impact on Future of CSR Payments"The decision does not mean that the Trump administration is barred from ending the cost-sharing reduction payments. It does mean, however, that the administration cannot unilaterally stop the CSR payments, dismiss the appeal, and claim judicial imprimatur for its doing so. If the administration does stop making the payments, the states -- or insurers, or possibly consumers -- would be able to sue to require the payments to be made and the injunction entered by the lower court would not be as much of a 'roadblock' to their prevailing." [House v. Price, No. 16-5202 (D.C. Cir. Aug. 1, 2017)] (Health Affairs)

Lawmakers to Hold Hearings to Stabilize Insurance Markets"[T]he Senate Health, Education, Labor and Pensions committee will hold bipartisan hearings on ways to stabilize the [ACA] marketplaces for 2018. The hearings will start the week of Sept. [4] Their aim is to act by Sept. 27, when insurers must sign contracts to sell individual insurance plans on HealthCare.gov for 2018." (National Public Radio)

After Changing Insurance Carriers, Do Patients Change Physicians and Use Emergency Departments More?"For patients initially covered by private insurance, changing carriers was associated with a nearly 50 percent increase in new [primary care physician] visits while visits to new specialists fell slightly. The overall decline in new specialist visits was caused by lower use among patients who faced higher deductibles after changing plans. These average utilization changes reflected larger changes in use shortly after the insurance switch that diminished over the subsequent year." (National Institute for Health Care Management [NIHCM])

Minimizing Risk of Out-of-Network Provider Litigation for Sponsors of Self-Insured Medical Plans"There are several actions that you should take immediately to minimize your risk: [1] Include a legally enforceable non-assignment of benefits clause in your plan document and summary plan description. [2] Provide for a time limit under which a participant may bring a suit for a claim in your plan document and summary plan description. [3] Delegate final claims adjudication responsibility to your third-party administrator in the services agreement and in practice. [4] Ensure that your ERISA plan documents and summary plan descriptions are up-to-date and well-organized." (Stevens & Lee)

[Opinion] Trump Move Would Boost Premiums, Raise Federal Costs, Destabilize Insurance Market"In threatening to stop making federal cost-sharing reduction payments (CSRs) to health insurers providing marketplace coverage, President Trump falsely claimed that they constitute an insurer 'bailout.' Actually, the federal government must make these payments to compensate insurers for reducing deductibles and copayments for low- and moderate-income marketplace consumers, as the [ACA] requires. Ending the CSR payments would boost premiums for many consumers, raise overall federal marketplace subsidy costs, and likely cause some insurers to withdraw from the marketplaces." (Center on Budget and Policy Priorities)

[Guidance Overview] The Emerging Contours of the Rules Governing Wellness Programs22 pages. "Whatever the form, these programs share a common need to navigate a shockingly complex legal and regulatory environment.... [A] basic structure for the regulation of wellness programs is still emerging. And the final EEOC rules, once they emerge, will almost certainly include some limitations with which employers disagree ... This article traces the development of the regulation of workplace wellness program design." (Alden J. Bianchi of Mintz Levin, via The Practical Lawyer)

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